In 2012, OSHA revised what they call the Hazard Communication Standard (HCS). The HCS establishes a standard for creating Safety Data Sheets (SDS) which were previously called Material Safety Data Sheets (MSDS).
The goal, according to OSHA was to establish “a consistent user-friendly 16 section format” for Safety Data Sheets. This is a worthy goal as the purpose of safety data sheets is to provide valuable safety information in case there is some type of emergency such as a fire or chemical exposure.
Have you ever really looked at the MSDS or SDS that you receive? They are anything but user friendly. I looked at one for a polycarbonate that said if you have skin contact with polycarbonate the affected area should be washed with soap and water for 15 to 20 minutes minimum. I’m not sure what negative health effects that you could have from touching polycarbonate but washing with soap and water for 20 minutes will certainly cause some adverse health effects. And, what exactly does sweet aromatic smell like any way? If there is a fire at my facility, do I call 911 and tell them to have the fire department bring carbon dioxide or water fog? What the hell is a sold extinguishing agent?
How about some information that ordinary people can use in an emergency and real advice for people to use to prepare their facilities for emergencies?
I am not going to bore you with step by step instructions for writing a safety data sheet. You can read the OSHA page here if you want that. What I want to cover is the areas of the SDS that are often confusing and to help people in our industry write better and clearer safety data sheets for your customers. The information that I am providing pertains specifically to plastic materials because that’s what this blog is about.
Here are few areas that I think require some clarification in order to make safety data sheets more user friendly.
Section 2: Hazards identification
Here, you are supposed to identify the potential hazards of handling the material. There are a couple of hazards in dealing with most plastic materials.
- If material gets overheated during processing, it can give off chemicals that can irritate the eyes and nose. This should be noted. If any of these chemicals such as formaldehyde from acetal are known carcinogens, this needs to be indicated as well.
- If melted material gets on your skin, it will cause burns.
- Dust from materials can irritate the eyes.
- There is a possible slip hazard from spilled pellets. Not sure that this is necessary to mention but you can mention it if you want.
Some other things are not really an issue:
- Unless, the material is in powder form, combustible dust is not an issue. Even non-flammable materials can become flammable if a lot of dust becomes airborne. Check out this video of exploding coffee creamer to see what I mean. Some plastics are dustier than others but it is extremely unlikely that you could get enough dust in the air to produce the circumstances needed to have an explosion.
- It is highly unlikely that anyone is going to eat or breath in enough plastic pellets to harm them. Silly to even mention this.
Section 4: First Aid Measures
OSHA says that this section “describes the initial care that should be given by untrained responders to an individual who has been exposed to the chemical” (emphasis mine). This should be basic stuff that people in your shop can do. Here are some suggestions:
- In case of fumes irritating the eyes or nose, remove the person to fresh air, either outside the shop or to a climate controlled office.
- If dust irritates the eyes, flush eyes with water or use an eye wash station if available.
- If a large amount of molten plastic gets on someone’s skin, rinse with cold water immediately to cool it. If the plastic is stuck on the person’s skin, do not try to pry it off, seek medical attention immediately.
- If you really want to cover your ass, you can put in some general statement about seeking medical attention if symptoms persist but I think everyone knows this.
Section 5: Fire Fighting Measures
This is the area that is the most confusing. I read one for acetal that says: use dry chemical, carbon dioxide, water spray, foam, water fog. Another for nylon says water, foam, dry powder, dry chemical, solid extinguishing agent.
One SDS for a PPO material simply says: “Extinguishing Media: WATER SPRAY, FOAM. CARBON DIOXIDE AND DRY CHEMICAL ARE NOT RECOMMENDED”
My reaction to this was: OK, what is recommended? I had to read it 5 times before I noticed that there is a period after the word foam so they are suggesting to use water spray or foam but not to use carbon dioxide or dry chemical. This is very confusing. It is also incorrect as dry chemical fire extinguishers will certainly put out PPO material that is on fire.
First of all, the fire department is going to use what they have available which is typically water. They may have nozzles that spray water in a stream or they may have nozzles that produce fog available. Some have foam systems which are pretty effective. However, you do not have time to shop and compare fire departments in your area when a fire is raging in your shop. Call 911 immediately, the fire department is the expert in fires and will figure out what to do when they get there.
The safety data sheet only needs to address what type of fire extinguishers that are needed in the area where the material is going to be stored and used in case someone notices a fire and needs to put it out before it gets too large and the professionals have to be called in.
The firefighting measures section of your SDS sheet should indicate one thing:
“Fire Extinguishers should be rated for Class A fires. Multipurpose class A, B & C fire extinguishers are also acceptable. The fire extinguisher should be dry chemical, water, water fog or foam type”
That’s it. Nothing else needs to be said here. This is clear useful information that a company can act on. They can make sure that they have the proper fire extinguishers.
Fire extinguishers are rated for the types of fires that they put out. There are special extinguishers for electrical fires, cooking oils fires and flammable liquid fires. Class A fires are “fires of ordinary solid combustibles which is what plastic material would fall under.
Section 9: Physical and Chemical Properties
This section includes a bunch of different properties of the material someone might need to know. The only problem that I have with many of the safety data sheets that I see is the description of the odor of the material.
Many safety data sheets for plastic materials attempt to describe the odor of the material when melted, but I am not sure if that is applicable. The properties should describe the material as it is when it comes from the manufacturer, not after it has been altered in some way. I suppose, you could indicate the odor in solid form and then the odor in melted form both if you wanted to, but this is probably unnecessary.
Also, some of the descriptions of the odors really don’t make any sense. I have no idea what “sweet aromatic” smells like and I also don’t know what a slight, specific odor is.
Most plastic materials have very little odor in solid form. The correct description for the odor is “minimal” or “slight” or even “none” or “odorless”. If the material is acetal, PVC or some other material that does have some odor in solid form, try and describe the smell in a way that the ordinary person can understand. For acetal, I would say “strong odor, smells like formaldehyde, might irritate eyes. PP and PE emit virtually no odor in solid form, but smell like candle wax when melted. Nylon emits almost no odor in solid form but smells a bit like baking bread when melted. TPV materials smell “rubbery” in solid form. Terms like rubbery and candle wax are things that people can understand.
OSHA has tried to standardize health and safety information in the form of the new safety data sheets and that’s great but I think maybe some additional guidelines would be helpful. A little clarification on what type of information is appropriate for a safety data sheet would help people understand the information, especially in an emergency situation.
Just keep in mind what the purpose of the safety data sheet is when you are putting them together. Your customer’s will appreciate it and you may help someone avoid an injury.